UNION OF INDIA vs BRIJ FERTILIZERS .

The Supreme Court held that the withholding of subsidy payments to small scale fertilizer manufacturers based on a report from PDIL, which was prepared without their participation, was unjustified. The Court found that the report could not be used to reject the manufacturers' compliance with the Fertilizer (Control) Order, as there was no evidence to doubt the inspectors' reports confirming the fertilizer met specified standards. The High Court's intervention at the show cause notice stage was deemed appropriate to protect the manufacturers from arbitrary action, leading to the dismissal of the appeal.